Privacy Statement

In this Privacy Statement, we have provided information about data collected and used when you:

• Purchase a Volkswagen vehicle or otherwise interact with Volkswagen and our Digital Properties, vehicles, products and services
• Receive Car-Net® Services (defined below).  

If you are the vehicle owner, you must notify any additional drivers about the privacy practices described in this Statement and if you are the Primary Driver for this vehicle’s Car-Net Services, you must notify any additional drivers of the vehicle about the Car-Net specific privacy practices described herein.

At Volkswagen of America, an operating division of Volkswagen Group of America, Inc., (“VW,” “we,” or “us”), we value your privacy and want you to know how your information will be handled and used.  This Privacy Statement applies to information we obtain from and about individuals interacting with VW websites, mobile applications, and other online services (collectively, our “Digital Properties”); VW vehicles, products and services; hardware and software in your VW vehicle that enables you to receive the personal assistance and telematics-based services provided through VW Car-Net (the “Car-Net Services”); and through other online and offline interactions with VW. However, this Statement does not apply to business contacts or VW job applicants or employees. The privacy statement for VW business contacts and job applicants can be found here.

This Statement does not apply to VW Credit, Inc. (“VCI”) or its products, contracts, and related services. VCI has its own privacy statement, which can be found here.

Below we provide a summary of the general information we collect, how we use it, and to whom it is disclosed. 

Table of Contents

1. From What Sources Do We Collect Information?
2. What Information Do We Collect?
3. How Do We Use Your Information?
4. To Whom Do We Disclose Your Information?
5. Cookies and Other Tracking Technologies
   
6. Mobile Applications
7. Our Commitment to Children’s Privacy
8. External Links
9. Security and retention
10. Changes to this Privacy Statement
11. DriveView™, Insurance-Related Data Sharing, and Vehicle Choices
12. Supplemental State Privacy Rights Information
13. Contact Us

As you interact with VW and its Digital Properties, vehicles, products and services, we may collect certain information from or about you or your vehicle from the following sources:

1. Directly from you or your vehicle, such as when you visit or use VW Digital Properties; use third-party digital properties (including social media sites and sweepstakes microsites); during other interactions such as product and related events, test drives, surveys, and promotion entries; and when you interact with our customer call centers.
2. Cookies and online technologies, such as when you access or use VW Digital Properties, third-party digital properties (including social media sites and sweepstakes microsites), or VW mobile applications.
3. Dealerships, including VCI (if you finance your VW vehicle purchase or purchase products from VCI) and other companies within the Volkswagen Group family of companies. 
   
4. Our affiliates, including VCI (if you finance your VW vehicle purchase or purchase products from VCI) and other companies within the Volkswagen Group family of companies.
5. Service providers, Integrated Content Providers and Optional Third Parties (defined in Sections 4.7 and 4.8 below).
6. Other third parties, such as companies that provide or sell lists of potential vehicle purchasers and current owners, data brokers, business partners (such as VW-authorized sellers of consumer merchandise), public sources, social media platforms and networks, or other parties that interact with us.

We may combine information that we receive from the various sources described in this Privacy Statement, including third-party sources, and use or disclose it for the purposes identified below.

As you interact with VW and its products and services, we collect different types of information from you based on the interaction, such as when you purchase a vehicle and subscribe to Car-Net services.
The types of information that VW collects about you include:

1. Basic Identifiers, including contact information; authentication information you create (such as a Volkswagen ID, date of birth, or other information to verify your identity); your preferences, photographs, user-generated content, and other materials that you may submit; demographic information; account and billing information, including financial data used for payment purposes; and profile information and settings (such as your preferences or information about personalized services).
2. Commercial Information, including:
   2.2.1 Contact information (such as name, address, telephone number, email);
   2.2.2 Vehicle purchase, lease or service information (such as VIN, make, model, year, dealer, date of purchase or lease, purchase/lease price, vehicle equipment, and service history);
   2.2.3 Vehicle usage information, such as vehicle data transmitted from your vehicle or collected or inferred from your use of the vehicle or services, including general vehicle status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle, including its identification, condition, equipment status, or collision information; vehicle/technology usage data (such as usage of lock/unlock and remote start technology); driver behavior data (such as vehicle speed, seat belt use, and information about braking habits); information that you provide when using Car-Net Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers, Integrated Content Providers, and Optional Third Parties related to your vehicle usage.
   2.2.4 Other purchasing or consuming histories or tendencies.
3. Electronic Information/Internet Activity, such as data gathered by tracking technologies when you visit our Digital Properties (as further described in Section 5 below) and information about your use of Car-Net Services, the Car-Net mobile application, and the Car-Net website. 
4. Geolocation data.
5. Sensory Data, such as call recording for emergency and customer service and voice command data (including any personal data included therein) and the transcripts of conversations you engage in with us via webchat, messaging apps, or social media.
6. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, demographics and vehicle usage patterns.

If your vehicle is equipped with an Event Data Recorder (“EDR”), crash or near-crash information about the vehicle or driver’s behavior will be recorded in the vehicle.  EDR data are recorded by your vehicle only if a non-trivial crash situation occurs, not under normal driving conditions. For information about your vehicle’s EDR data or other crash or near-crash information collected and how we might receive and use it, please see your owner’s manual. 

We collect and use your information for a number of business purposes, such as:

1. To provide you with products and services, such as to provide products and services you request; support your vehicle, products, and services; diagnose, repair, and track service and quality issues; communicate with you about your vehicle, products, or services; install and configure changes and updates to your services; authenticate users of our products and services; verify your eligibility for certain programs or benefits; or to provide you with Car-Net Services. 
2. For our own internal business purposes,  such as to evaluate the usage, performance, and safety of our vehicles, products, and services; improve the quality of our vehicles, products, and services and design new products and services; operate our Digital Properties and customize the content; to maintain internal records; also for auditing; debugging; short-term transient use; internal research; and quality assurance.
3. For legal, safety or security reasons, such as to comply with legal requirements; protect the safety, property, or rights of VW and the Volkswagen Group family of companies (such as VCI’s right to repossess its vehicles, including by using GPS data) and those of owners, registered users, drivers, passengers or others; or to prevent and detect fraud or misuse of the vehicles, products, or services.
4. For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties, including through interest-based advertising as described in Section 5. However, please note that we will not use or disclose precise GPS location data or your driver behavior data for our own marketing purposes or for the marketing purposes of unaffiliated third parties without your affirmative consent.
5. In a de-identified or aggregated format, we may also use or disclose your information in a de-identified or aggregate manner for any purpose.

We also provide your information to third parties who use it for the commercial purpose of marketing their products and services to you.

Please note that for MY19 and older vehicles, we will only use GPS location for purposes of providing Car Net Services to subscribers, complying with legal process, or as otherwise required by law. 

We may disclose your information:

1. Within the Volkswagen Group family of companies. We may disclose your information to Volkswagen Group parents, corporate affiliates, subsidiaries, business units, and other companies that share common ownership (including Volkswagen AG, which is located outside of the United States, and VCI). 
2. To our service providers. We may disclose your information to service providers that work on behalf of VW, such as advertising agencies, third parties that assist us with marketing efforts, emergency responders, IT providers, customer support, and call center service providers.
3. To Authorized Dealerships. We may disclose your information to VW dealers for sales, leasing, and customer service purposes, such as responding to quote requests; for vehicle diagnosis, maintenance, and repair; to schedule service appointments; and to contact you and provide your requested services.
4. To others for legal, security or safety purposes. We may disclose your information to third parties, law enforcement, or other government agencies to comply with law or legal requirements; to enforce or apply our Terms of Service and other agreements or those of the Volkswagen Group family of companies; and to protect our rights and the property or safety of our users or third parties. We also may disclose information about you and your vehicle when we have reason to believe that someone is causing injury to or interference with the rights or property of VW, other users of the Digital Properties, or anyone else that could be harmed by such activities.
5. To other companies in connection with a VW corporate transaction. We may disclose your information if some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, in which case we will disclose the information we hold to that company. 
6. To third parties for their own marketing purposes. We may disclose your contact information and vehicle identification data to third parties for their own marketing purposes, such as Sirius XM, VW Dealers, and select companies with whom we may partner to offer you products or services.  
7. To Integrated Content Providers. We may disclose your information via the Car-Net® Services to various third parties with whom we contract and to whom you directed us to disclose personal information to provide products and services through VW vehicles (“Integrated Content Providers”) whose services are integral to the Car-Net Services, and without which many of the Car-Net Services would not work.  VW does not create or control the content offered by these Integrated Content Providers, nor does VW determine how they handle your personal information for purposes of providing their services.  The Integrated Content Providers are exclusively responsible for the content and the availability of the content accessible through the Car-Net Services. Integrated Content Providers have the right to use your data for their own purposes and therefore, services from Integrated Content Providers will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use, or disclosure of your personal information by Integrated Content Providers or wish to exercise any rights that you have, please contact the relevant Integrated Content Provider directly at the web address provide below. VW collects and discloses information to these Integrated Content Providers and receives information from these Integrated Content Providers for the purposes described above and in order for you to receive the services and/or content requested.  
   
   The following is a list of the current Car-Net Integrated Content Providers and their respective websites and contact information. This list is subject to change without notice. 
   
   – Google Inc., for point-of-interest searching (POI), including voice control, and navigation with Google Earth images : Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA –
 https://policies.google.com/privacy
   
8. To Optional Third Parties. In addition to the Integrated Content Providers’ services available as part of the Car-Net Services, we may disclose your information to other third parties from which you can obtain or purchase additional services or offerings that we introduce or with whom you independently engage that rely on the Car-Net platform (“Optional Third Parties”).  These Optional Third Party services are not integral to the basic operation of Car-Net Services, but may be added by you in order to receive additional services and/or content from the Car-Net platform. The Optional Third Parties contract directly with you and are exclusively responsible for their services accessible through the Car-Net platform. Optional Third Parties have the right to use your data for their own purposes and therefore, services or offerings from such Optional Third Parties will be subject to their Terms of Service and Privacy Statement. If you have any concerns regarding the collection, use, or disclosure of your personal information or if you wish to exercise any rights that you have, please contact the Optional Third Parties directly. Examples of Optional Third Parties include remote package, fuel or other in-vehicle delivery, car sharing, tolling pricing, usage-based insurance, or other third-party services.
9. To third-party entities that provide online advertising and analytics functionality and technologies. We may disclose your information to third parties that provide advertising and analytics services, as further described in Section 5 below.
10. With other third parties that you direct or provide consent. 

Our Digital Properties (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about: 

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
  
• How we disclose or make information available to others
• Choices you may have regarding these technologies

1. Types of cookies and tracking technologies we use
   Our Digital Properties and the third parties that we authorize may use the following tracking technologies:
   
   - Cookies, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.  
   
   - Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described in Section 5.2 below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages. 
   
   - Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described in Section 5.2 below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
2. Purposes for using these technologies 
   We and authorized third parties use these technologies to remember user preferences, login details and browsing behavior; improve the performance of our Digital Properties, products, and services; conduct analytics; provide you with offers that may be of interest to you; track your activity across online properties over time to better understand your preferences and interests; to conduct advertising on our Digital Properties and those of third parties; measure the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with one of our emails; and personalize online content.  For example, we use Google Analytics to help us improve our Digital Properties, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services.  To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
3. Information collected 
   These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed). 
4. Disclosures of your information 
   VW may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties. 
5. Your choices
   Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a VW advertisement and follow the instructions on how to opt out.
   
   You can also refuse or delete cookies using your browser settings.  If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired.  Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.  If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from VW or its agents or representatives.
   
   Some browsers have incorporated Do Not Track (“DNT”) preferences. Because there is no universal standard of how to apply that setting, we currently do not honor them.

In addition to mobile applications designed to allow you to use your Car-Net® Services, VW may have mobile applications that you can download to your mobile device or vehicle (“VW Applications”). When you download a VW Application, there may be an opportunity for you to provide us with or for us to obtain information about you or your vehicle. Each VW Application will display a Privacy Statement that will inform you about how any new or different information disclosed via the application will be handled.  Otherwise, information collected via VW Applications will be the information identified above and will be used and disclosed as stated in this Privacy Statement.

Through the Infotainment system, VW may also offer applications developed by third parties, for example Apple CarPlay or Android Auto (“3rd Party Application”). When you download a 3rd Party Application to your mobile device or vehicle, the 3rd Party Application may collect information about you or your vehicle in connection with your download or use of that application. VW is not responsible for the collection or use of information by 3rd Party Applications. We recommend that you carefully review the privacy statement and terms of use of each 3rd Party Application prior to downloading or using them. 

VW does not knowingly collect, use, disclose, or sell the information of children under the age of 16. In the event that we learn that we have collected information from a child under age 16, we will delete that information.  For questions or additional information, please contact us using the information in Section 13 below.

The Digital Properties may contain links to other websites, including social networks, advertisers, VW Dealer websites, VCI websites, other Volkswagen Group websites, other websites operated by VW AG, and websites belonging to other third parties. Some of these sites may share a similar “look and feel” to our Digital Properties. Please be aware that we are not responsible for the privacy practices of other websites. We encourage you to read the privacy statements provided by other websites before you provide information to them. 

VW maintains reasonable safeguards to protect your information.  Some services, including Car-Net® Services, may involve the transmission of voice and data from your VW vehicle over wireless and cellular telephone networks and therefore, we cannot guarantee the privacy and security of conversations or data transmitted to and from your VW vehicle.

 Your information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety, and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as  to demonstrate our business practices and contractual obligations or provide you with information about our products and services in case of interest. 

From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you periodically to check this site to learn about the information we collect, use, and disclose. Your continued use of any of our Digital Properties, products or services affirms your agreement to such changes.

1. DriveView™
   Car-Net users will also be enrolled in DriveView. As part of the DriveView service, VW will use Commercial Information and Electronic Information collected through Car-Net Services about your driving behavior, such as speed, braking and GPS location in order to assess your driving and routinely provide you a DriveView score (i.e. a score based on certain factors that are considered higher indicators of risk of collision, such as hard braking, nighttime driving, idle time and high speed).  We will collect this data directly from you and your use of the Car-Net technologies. For more information, please review the DriveView Terms of Service. You can opt-out of DriveView at any time by following the instructions outlined in the Vehicle Choices section below.
2. Insurance-Related Data Sharing
   DriveView users can also opt-in to insurance-related data sharing to be considered for insurance discounts. If you opt-in, we will disclose certain Commercial Information, including GPS location, driver behavior, and other data as described here to the insurance-related companies listed here. We do not control how such insurance-related companies use your data. You can learn more about how those companies use your data by reviewing their privacy statements. If you choose to opt-in to insurance-related data sharing, we will provide your driving behavior, GPS location, and other data described in this section for 20 days (or for a longer period of time until you have completed 20 trips in your vehicle). If you opt-out at any time during this period, we will stop providing your data to insurance-related companies. For more information, please review the DriveView Terms of Service. You can opt-out of insurance-related data sharing at any time by following the instructions outlined in the Vehicle Choices section below.  
3. Vehicle Choices
   DriveView: You can cancel or terminate your DriveView Service at any time by visiting your DriveView account profile on the Car-Net Website or the myVW mobile app and following the instructions to unenroll from DriveView, or by calling a DriveView customer service representative at 1-833-648-2735. Please note that if you unenroll from DriveView, you will no longer receive DriveView scores or feedback on how you are driving, and your driving data will no longer be shared with insurance-related companies if you have opted-in to insurance-related data sharing.
   
   Insurance-Related Data Sharing: You can also opt-out of insurance-related data sharing at any time by switching off “Third Party Data Sharing” on the Car-Net Website or the myVW mobile app under Account > Vehicle Management > DriveView, and following the instructions to unenroll from insurance-related data sharing.
   
   Car-Net: You can discontinue the Car-Net Services data collection described in this Privacy Statement at any time by unenrolling your vehicle from Car-Net. However, this will result in loss of Car-Net Services, including DriveView and insurance-related data sharing (if you have opted in). You can unenroll from Car-Net via the Car-Net website, myVW mobile app or by calling Car-Net Response Center at 1-833-648-2735.
   
   Please note that the information stored in your VW vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your VW vehicle or mobile device, and thus may be deleted, altered, or transferred. 
   
   Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle. Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.

In addition to the details provided above about the information we collect and how we use and disclose it, below is a list of the categories of personal information collected and for each category, the categories of third parties to whom we disclosed it for a business or commercial purpose (as defined under applicable law).

We disclose information for targeted advertising purposes and in other situations that may constitute a "sale" or “sharing” as defined under applicable law.

We only use Sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; and/or (vii) verifying or maintaining the quality or safety of a service or device.

Your State Privacy Rights

Depending on where you live, you may have certain rights, subject to legal limitations, regarding the collection, use, and disclosure of your personal information. You can submit a Data Subject Rights Request by visiting privacy.vwgoa.com and following the instructions in the portal, or by calling (833) 909-1767.
Please note that certain rights may be limited where your personal information is subject to certain state or federal laws, such as the Fair Credit Reporting Act (“FCRA), the federal Gramm-Leach-Bliley Act (“GLBA”), or state law equivalents.

1. Right to Opt-Out of Sale/Sharing/Targeted Advertising
   Depending on where you reside, you may have the right to opt-out of the “sale” or “sharing” of your personal information and/or targeted advertising . In order to fully exercise the Right to Opt-Out of Sale/Sharing/Targeted Advertising, you must undertake both of the following steps:  
   - Submit an Opt-Out of Sale/Sharing/Targeted Advertising request by going to privacy.vwgoa.com and following the instructions in the portal, or calling (833) 909-1767.
   
   - Disable Sale/Sharing/Targeted Advertising in the Preference Center, which will place a cookie on your browser signaling that you have opted out of such online activities. Please note: 
   
       -The opt-out cookie applies only to the Digital Property you are accessing and the browser and device you are using at the time you make the Preference Center selection. You will also need to disable “Sale/Sharing/Targeted Advertising” in the Preference Center from each browser on each device you use, and on each Digital Property you access.   
       - If you clear cookies on your browser, you will need to disable the “Sale/Sharing/Targeted Advertising” toggle in the Preference Center from that browser again.    
       - If you have blocked cookies through your browser settings, we will be unable to comply with your Preference Center opt-out request. 
   
   To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level. 
   
   Nevada residents:  Please contact us at privacy@vw.com to inquire about your right to opt out of the sale of your personal information.
   
2. Right to Delete
   You may have the right to request that we delete personal information that we maintain about you. 
3. Right to correct
   You may have the right to request that we correct inaccurate personal information that we maintain about you.
4. Right to Know
   You may have the right to request that we disclose personal information that we have about you. You can request that we provide you with the categories of personal information we have about you, and information about how we used and disclosed those categories of information. You may also request that we provide you the specific pieces of personal information that we have about you. Oregon residents may also request a list of the third parties to whom we have disclosed personal information.
5. Verification
   In order to verify your identity, match you to our records, and reduce fraud, we will ask you for your personal information or information about you. We also use third party verification companies to help us verify your identify. You will need to provide certain pieces of information to enable us to verify your identity. In order for us to process your request, the information you provide must match our records in a manner that we have determined to be reliable. We may also ask you to provide a declaration, signed under penalty of perjury, certifying that you are the person whose personal information is the subject of the request. 
6. Use of authorized agent
   Authorized agents may exercise rights on behalf of consumers by calling 844-987-2272. We will require agents to provide written authorization from the consumer along with completing any other verification requirements described above.  
7. Timing of Response
   We will process Requests to Opt-Out of Sale or Sharing within 15 business days. We will respond to all other Data Subject Rights Requests within 45 calendar days, unless we need more time (up to 90 days total), in which case we will notify you.
   In accordance with applicable law, we will not discriminate against you for exercising your privacy rights.
8. Appeals
   If we deny your rights request, you may have the right to appeal. To submit an appeal, you may contact us at 844-987-2272. 

Should you have other questions or concerns about this Privacy Statement, please email us at: privacy@vw.com.

You may also contact us by phone 24 hours a day, at: 1-800-822-8987. 

And by mail at:
Office of General Counsel
Volkswagen Group of America
Attn: Privacy Office
1950 Opportunity Way
Reston, VA 22191

If you would like to opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email.  Opting out of promotional email will not affect VW’s communication with you by email about your vehicle or other product or service-related matters.